Document bawxJ5mVkzxa6dybX6kL14nXy

TO: R. D. Gamblin Interoffice Communication FROM: DATE: SUBJ: T. G. Grumbles September 14, 1990 PROGRESS REPORT VISTA 1. TGG participated in a meeting at R&D to review the final draft of the revised New Product Development Manual and begin plans for training on the revised procedures. 2. EPA is continuing efforts to move towards a "Product Stewardship" rulemaking under the TSCA rules umbrella. Content of the rule is very preliminary at this time but the EPA staff has indicated that there will be requirements for full lifecycle assessments on identified chemicals. The 313 list will probably be used as the initial screening list. 3. A conference call was held with SDA member companies to determine how to deal with EPA's recent indication that a formal delisting petition would be required to get "surfactant" range materials excluded from the 313 glycol ether definition. SDA counsels are preparing a detailed menu regarding our legal options. We are also working on an alternate glycol ether definition that could be proposed to EPA to exclude the surfactant materials. 4. ERT assisted S&T and LCCP in their evaluation of the Eastlake Storage Terminal No. 2 in Lake Charles. The facility appears to be acceptable for the product that we are proposing to store there. This approval is based on the provision that certain issues on air, wastewater permitting, emergency procedures and SPCC Plan revisions are resolved prior to start up of operations. T. G. Grumbles dlj VVV 000013750 Vista Chemical Company 900 Threadneedle Houston, Texas 77079 (71 3} 588-3000 P.O. Box 19029 Houston, Texas 77224 Fax (71 3) 588-3236 September 14, 1990 Jeffrey S. Lee, Ph.D. c/o Applied Industrial Hygiene, 6500 Glenway Avenue, Bldg. D-7 Cincinnati, Ohio 45211-4438 Inc. TGGrjet: ERT: XF: VISTA Re: Manuscript No. 9038 Dear Jeff: I've reviewed the other reviewers review (did that make sense?) and have the following thoughts. I believe our thoughts on the quality of the paper were very similar with only a one number difference in our "scientific/technical merit" rating. I had more problems with the manuscript form and content but many of the general comments were the same. However, until significant changes are made in the data summary, and in some cases, description of data sources, I have a problem with the scientific merit of the paper. I'd be willing to go to a 5 rating. That probably gets us to the same place in that we both will be reviewing the paper again. Please let me know what you want me to do. Sincerely, Thomas G. Grumbles, C.I.H. Manager Environmental Affairs dlj VVV 000013749 r Question 15. In your experience, have CMA documents usually been submitted A B C D E-ITotal Early On Time Late 00 1 1 19 10 9 17 0 10 1 1 12 0 3 67 2 Question 16. With regard to public: expectations on issues , are CMA positions most often: A B C D E-I Total Ahead of Public expectations 32202 9 In synch with public expectations 7429 6 28 Behind Public expectations 9567 7 34 Question 17. When compared to those of other industries, CMA positions are most often: ABC D E-I Total Less Progressive Equally Progressive More Progressive 1 002 0 884 7 6 10 3 6 7 8 3 33 34 Question 18. If you could give CMA one piece of advice to improve its regula tory advocacy, what would that be? The most frequent responses were: o early identification and involvement with issues o more networking with other trade associations o better communication with members (not more paper) o more personal visits to agencies o more member company involvement o more direct outreach to members Question 19. How could CMA obtain better input from small member companies? The most frequent responses were: o more meetings outside DC o develop a participation requirement based on member size o more member involvement o closer relationship with SOCMA andCSMA o more workshops o develop polling system or short survey system o establish small company forum/focus groups vvv 0000137*8 Question 10* Is your company a member of other trade associations that conduct federal regulatory activity? Responses are collected both as the average number of membership per size of firm and the most frequently mentioned associations. Average # of Memberships Firm Size A B C D E-I 8.8 7.3 3.9 2.4 2.6 Question 11. How would you rate CMA's regulatory advocacy effectiveness in each issue area? Responses are graded based on Che first and second most frequent response A single mark is assigned for responses in excess of 802 . The response categories are: H = High, A = Average, L * Low, N * No Idea. Size Firm A B C D E-I Overal1 AH AH AH AH AH Environmen ta1 AH AH HA HA HA Health & Safety AH AH AH HA AH Distribution AH A AH AH AH Energy LA AN A AL AL Question 12. Is CMA's regulatory advocacy on par with other trade associations? Responses are graded by the first and second most frequent response, one grade is given when a response occurred in more than 8021 of the response The marks are: B = Better, E = Equal, L = Less than, N =; No Idea. Size Firm A B C D E-I Environmental BE BE BE BE BE Health and Safety BE EL EB BE EB Distribution BE EL EB EB EB Energy EL NE NE EB EN Overall EB EB BE EB BE VVV 000013746 Question 4. If your company did not participate in regulatory advocacy, either through or for CMA, for any issue areas listed below, please indicate that what barriers exist for your company's participation. Responses on this question were limited to the firms not conducting federal regulatory activities, therefore, only nine companies responded. Of those, the most frequent responses were: 1) Limited company resources 2) Participate in other trade groups 3) Viewed as a "big company" task. Question 5. What are the barriers to providing additional company staff for CMA related federal regulatory advocacy? Responders indicated that they did not have personnel with sufficient time available to conduct more advocacy. Many also indicated that they did not see a clear return on their investment for more advocacy efforts. Question 6. What is your perception of how CMA currently sets priorities on selected issues and how should they set priorities for regulatory advocacy? Responses were not very different from group to group, in general, the members said that in the current system CMA sets priorities as follows: 1) Committees or Task Groups set Priorities 2) Issues with large economic impact on industry have the highest priority 3) Issues that can set a major precedent have the highest priority 4) Big companies set priorities All categories of firms agreed that tha following factors were the correct ones for setting priorities. 1) Issues with large economic impact on industry have the highest priority. 2) Issues that can set a major precedent have the highest priority. 3) Committees or Task Groups set priorities. Question 7. What parts of the regulatory advocacy process are most important and which ones should CMA emphasise more? Responses were consistent among the categories of firms with the following as the top 5 responses on the most important parts of the regulatory process: 1) Write coonents on proposed rules 2) Issue identification 3) Staff and company visits to agency to inform of CMA positions 4) Establish industry positions 5) Inform the members of significant issues Respondents said that CMA should emphasize more of the following elements: 1) Staff and company visits to agency to inform of CMA positions. 2) Provide a forum for the development of industry positions 3) Inform the members of significant issues 4) Coordinate the Industry position with others 5) Collect information about the chemical industry to support advocacy REGULATORY ADVOCACY SURVEY SUMMARY OF MEMBER COMPANY RESPONSES The following is a summary of Che responses co a survey of all member companies designed co determine cheir activities in federal regulatory advocacy. The overall response rate was SOZ. The response race for companies with chemical sales in excess of $100 million was 71Z. For companies with sales of less than $100 million, the response rate was 21Z. -In order to determine differences in levels of effort and opinions, many of the responses are categorized by size of firm. For ease in reading the companies are categorized as: Chemical Sales In Millions Size A Size a Size C Size D Size E Size F Size G Size H Size I >$2,000 1,000 - 2,000 400 - 1,000 100 - 400 50 - 100 25 - 50 10 - 25 10 - 15 < Iff VVV 0000137*2 Size through I were aggregated in this summary to keep the groupings of roughly equal size. Question 1. Does your company conduct federal regulatory advocacy? Of all respondents, 78 firms indicated that they conducted federal regu latory activity. Eight firms responding indicated they did not partici pate in federal regulatory advocacy. Responses are summarised by the numbers of individuals in each category for each grouping of companies. The numbers in parenthesis are the average number of individuals in each category per company. The catego ries are 5-20Z, 20-50Z and >50Z of an individual's time. HO A Size A 5-20Z 412 (19) 20-50Z 66 (3) 35 (2) Size B 119 (10) 21 (2) 7 U) Size C Size D Size E-I Total 71 16 7 (6) (2) (1) 66 16 4 (4) (1) (0.2) 14 3 2 (1) (0.2) (0.1) 702 126 55 REGULATORY ADVOCACY SURVEY SUMMARY OF MEMBER COMPANY RESPONSES The following is a summary of the responses to a survey of all member companies designed to determine their activities in federal regulatory advocacy. The overall response race was 50Z. The response race for companies with chemical sales in excess of $100 million was 71X. For companies with sales of less chan $100 million, the response rate was 21Z. .In order to determine differences in levels of effort and opinions, many of the responses are categorised by size of firm. For ease in reading the companies are categorized as: Chemical Sales In Millions Size A Size B Size C Size D Size E Size F Size G Size H Size I >$2,000 1,000 - 2,000 400 - 1,000 100 - 400 50 - 100 25 - 50 10 - 25 10 - 15 < ia vvv 000013742 Size E through I were aggregated in this summary to keep Che groupings of roughly equal size. Question 1. Does your company conduct federal regulatory advocacy? Of all respondents, 78 firms indicated that they conducted federal regu latory activity. Eight firms responding indicated they did not partici pate in federal regulatory advocacy. Responses are summarized by the numbers of individuals in each category for each grouping of companies. The numbers in parenthesis are the average number of individuals in each category per company. The catego ries are 5-20Z, 20-50Z and >50% of an individual's time. Size A 5-20X 412 (19) 20-50X 68 (3) >50X 35 (2) Size B 119 (10) 21 (2) 7 (1) Size C 71 18 7 (6) (2) (1) Size D Size E-I Total 86 16 4 (4) (1) (0.2) 14 3 2 (1) (0.2) (0.1) 702 126 55 Question 2. Does your company measure success in federal regulatory advocacy? Almost all responses were affirmative, and most all indicated the measure of success was the degree to which the agency took our comments into account in the final regulations. Question 3. For federal regulatory advocacy that you conducted through or for CMA in the past year, please indicate the number of persons involved by agency and by the approximate percentage of time those persons spend. Responses are summarized by size with the totaL number of individuals in each group and the average number of individuals per company in parenthe sis immediately following the group totals. See Figure 1. Size A firms: Environmental OSH Distribution Energy Ocher Size B firms: Environmental OSH Distribution Energy Other Size C firms: Environmental OSH Distribution Energy Other Size D firms: Environmental OSH Distribution Energy Ocher Size E-I firms: Environmental OSH Distribution Energy Other Total: 5-20X 153(6.9) 93(4) 45(2) 19(1) 20(1) 33(2.4) 21(1.5) 22(1.5) 9(0.7) 2(0.15) 19(1.6) 15(1.3) 6(0.45) 1(0.09) 0 41(1.7) 20(1) 12(0.5) 4(0.1) 4(0.1) 5(0.6) 2(0.4) 3(0.5) 0 0 548 20-50Z 25(1) 20(0.8) SCO.3) 2(0.1) 3(0.2) 6.5(0.5) 1(0.08) 2(0.15) 0 1(0.08) 8(0.7) 7(0.6) 1(0.09) 1(0.09) 0 6(0.3) 2(0.1) 1(0.1) 0 1(0.1) 3(0.5) 1(0.1) 3(0.5) 0 1(0.1) 99.5 >501 17(1) 5(0.3) 0.2(0.1) 2(0.1) 2(0.1) 2(0.15) 0 0 0 0 2(0.18) 1(0.09) 1(0.09) 0 0 0 1(0.1) 0 0 1(0.1) 0 0 0 0 0 34 VVV 000013743 Question 4. If your company did not participate in regulatory advocacy, either through or for CMA, for any issue areas listed below, please indicate that what barriers exist for your company's participation. Responses on this question were limited to the firms not conducting federal regulatory activities, therefore, only nine companies responded. Of those, the most frequent responses were: 1) Limited company resources 2) Participate in otheT trade groups 3) Viewed as a "big company" task. Question 5. What are the barriers to providing additional company staff for CMA related federal regulatory advocacy? Responders indicated that they did not have personnel with sufficient time available to conduct more advocacy. Many also indicated that they did not see a clear return on their investment for more advocacy efforts. Question 6. What is your perception of how CMA currently sets priorities on selected issues and how should they set priorities for regulatory advocacy? Responses were not very different from group to group, in general, the members said that in the current system CMA sets priorities as follows: 1) Committees or Task Croups set Priorities 2) Issues with large economic impact on industry have the highest priority 3) Issues that can set a major precedent have the highest priority 4) Big companies set priorities All categories of firms agreed that the following factors were the correct ones for setting priorities. 1) Issues with large economic impact on industry have the highest priority. 2) Issues that can set a major precedent have the highest priority. 3) Committees or Task Croups set priorities. Question 7. What parts of the regulatory advocacy process are most important and which ones should CMA emphasise more? Responses were consistent among the categories of firms with the following as the top 5 responses on the most important parts of the regulatory process: 1) Write comments on proposed rules 2) Issue identification 3) Staff and company visits to agency to inform of CMA positions 4) Establish industry positions 5) Inform the members of significant issues Respondents said that CMA should emphasise more of the following elements: 1) Staff and company visits to agency to inform of CMA positions. 2) Provide a forum for the development of industry positions 3) Inform the members of significant issues 4) Coordinate the Industry position with others 5) Collect information about the chemical industry to support advocacy Question 8. How effective ere CMA communications with the regulatory agencies Responses are given by fi rm size groups with the top ranked each category as follows: L = Limited, G = Good, P * Poor Firm Size A B C D E-I Environmental GL GL LG GL GP Health & Safety LG LG L GL LC Distribution LG GL LG GL L Energy LG LG LC GL LP Question 9. Please rate the effectiveness of the following groups in <conducting federal regulatory advocacy. Responses were rated as the 1st and 2nd most frequent response as follows (a single mark was given when more than 752 of the responses were the same) H = High, A = Average, L = Least Effective, X = Don't Know A B C D E-I Public Interest Research Group AH AH X XA AH American Petroleum Institute A AH AH AH AH Citizen Labor & Energy Coalition X X X XX National Association of Manufacturers A AH A AH AH Chemical Manufacturers Association AH AH A AH HA National Resources Defense Council H H HA HA HA National Wildlife Federation AH HA HA HA HA Consumers Federation of America AX AH AH XA X Syn. Organization Chem. Man. Assoc. A A A AH AH Electricity Cons. Res. Council XA X X X X Coalition to Oppose Energy Taxes XA X X X X Chemical Specialty Man. Association AL AL AL XL AX American Paper Institute AX A AH XH XL U.S. Chamber AL AL LA AH AL American Industrial Health Council AH A AL XA XL American Institute of Chemical Eng. AL LA LA LA AL Association of American Railroads AH HA AH XA AL Environmental Defense Fund HA HA HA HA HA Sierra Club HA HA HA HA HA American Trucking Associations AH AH AH LA XL Petrochemical Ener. Group XL X X XA XL Process Gas Consumers XA X X XA XL National Agri. Chemical Association AH AH X XA XA AFL/CIO AH AH HA HA HA Question 10. Is your company a member of other trade associations that conduct federal regulatory activity? Responses are collected both as the average number of membership per size of firm and the most frequently mentioned associations. Average # of Memberships Firm Size A B C D E-I 8.8 7.3 3.9 2.4 2.6 Question 11. How would you rate CMA's regulatory advocacy effectiveness in each issue area? Responses are graded based on the first and second1 most frequent response A single mark is assigned for responses in excess of 80Z . The response categories are: H = High, A = Average, L = Low, N1 = No Idea. Size Firm A B C D E-I Overal1 AH AH AH AH AH Environmental AH AH HA HA HA Health & Safety AH AH AH HA AH Distribution AH A AH AH AH Energy LA AM A AL AL Question 12. Is CMA's regulatory advocacy on par with other trade associations? Responses are graded by the first and second most frequent response, one grade is given when a response occurred in more than 80Z of the response The marks are: B = Better, E = Equal, L = Less than, N = No Idea. Size Firm A B C D E-I Environmental BE BE BE BE BE Health and Safety BE EL EB BE EB Distribution BE EL EB EB EB Energy EL NE NE EB EN Overall EB EB BE EB BE VVV 000013746 Question 13 In your opinion, what would improve CMA's regulatory advocacy? Responses are marked with the first and second most frequent response except when one response was marked more than 80Z of the time. Responses allowed were: H - High Need, M Medium Need, L - Low Need. Pin Size A B C D E-I More Member Company Participation HM MM H HM HM Better Member Company Training MH MH MH MH MH More Professional Staff Support M LM LM LM LM More Board Level Involvement More Support Staff Better Staff Training More Outside Consulting Services LM ML HM MH LM ML L LM LM LM LM ML LM LM ML LM L L LM L More Data From Companies HM MH MH LM HM More Information about Early Agency Efforts More Networking with other Trade Associations More Networking with Professional Societies HM H HM HM HM M HM HM HM HM ML MH ML HM M More Outreach to Academics ML ML M MH LM More Seminars and Workshops for Company ML ML LM MH HM Personnel More Regulatory Economics Capability MH MH M ML LM Better Coordination Between Committees MH ML M and Task Groups M ML Question 14. At what stages of regulatory development can you normally expect CMA to become involved? firm Size A B P D R-I Total Preproposal Proposal Post Proposal Litigat ion/Settlement 12 4 67 10 00 3 7 0 0 13 11 74 00 00 43 31 1 0 VVV 0000X3747 Question IS In your experience, have CMA documents usually been submitted A B C D E-ITotal Early On Time Late 001 1 19 10 9 17 0 10 1 1 12 0 3 67 2 Question 16. With regard to public: expectations on issues , are CMA positions most often: A B c D E-I Total Ahead of Public expectations 32202 9 In synch with public expectations 7429 6 28 Behind Public expectations 95 6 7 7 34 Question 17. When compared to those of other industries, CMA positions are most often: ABC D E-I Total Less Progressive Equally Progressive More Progressive 10020 88476 10 3 6 7 8 3 33 34 Question 18. If you could give CMA one piece of advice to improve its regula tory advocacy, what would that be? The most frequent responses were: o early identification and involvement with issues o more networking with other trade associations o better communication with members (not more paper) o more personal visits to agencies o more member company involvement o more direct outreach to members Question 19. How could CMA obtain better input from small member companies? The most frequent responses were: o more meetings outside DC o develop a participation requirement based on member size o more member involvement o closer relationship with SOCMA andCSMA o more workshops o develop polling system or short survey system o establish small company forum/focus groups VVV 0000137^B Vista Chemical Company 900 Threadneeale Houston, Texas 77079 (713) 588-3000 P.O. Box 19029 Houston, Texas 77224 Fax (713) 588-3236 September 14, 1990 TGGr JSt: ERT: XF: A RF Jeffrey S. Lee, Ph.D. c/o Applied Industrial Hygiene, 6500 Glenway Avenue, Bldg. D-7 Cincinnati, Ohio 45211-4438 Inc. Re: Manuscript No. 9038 Dear Jeff: I've reviewed the other reviewers review (did that make sense?) and have the following thoughts. I believe our thoughts on the quality of the paper were very similar with onlv a one number difference in our "scientific/technical merit" rating. I had more problems with the manuscript form and content but many of the general comments were the same. However, until significant changes are made in the data summary, and in some cases, description of data sources, I have a problem with the scientific merit of the paper. I'd be willing to go to a 5 rating. That probably gets us to the same place in that we both will be reviewing the paper again. Please let me know what you want me to do. Sincerely, A ------------------- Thomas G. Grumbles, C.I.H. Manager Environmental Affairs dlj VVV 000013749 TO: R. D. Gamblin Interoffice Communication FROM: DATE: SUBJ: T. G. Grumbles September 14, 1990 PROGRESS REPORT VISTA 1. TGG participated in a meeting at R&D to review the final draft of the revised New Product Development Manual and begin plans for training on the revised procedures. 2. EPA is continuing efforts to move towards a "Product Stewardship" rulemaking under the TSCA rules umbrella. Content of the rule is very preliminary at this time but the EPA staff has indicated that there will be requirements for full lifecycle assessments on identified chemicals. The 313 list will probably be used as the initial screening list. 3. A conference call was held with SDA member companies to determine how to deal with EPA's recent indication that a formal delisting petition would be required to get "surfactant" range materials excluded from the 313 glycol ether definition. SDA counsels are preparing a detailed menu regarding our legal options. We are also working on an alternate glycol ether definition that could be proposed to EPA to exclude the surfactant materials. 4. ERT assisted S&T and LCCP in their evaluation of the Eastlake Storage Terminal No. 2 in Lake Charles. The facility appears to be acceptable for the product that we are proposing to store there. This approval is based on the provision that certain issues on air, wastewater permitting, emergency procedures and SPCC Plan revisions are resolved prior to start up of operations. T. G. Grumbles dlj VVV 000013750 r